On March 23rd, the NMOCD posted on its website a notice to all operators requesting information relating to wellbore(s) that have communicated with another wellbore(s) to the appropriate OCD office by April 22nd. The NMOCD states, “there has been evidence showing that inter-well communication and/or pressure increases may injure producing formations, injection intervals, casing or case seats and may create underground waste.” The request of the NMOCD requires all operators to give the agency information regarding “communication of any kind through drilling, completion, stimulation or production operations relating to both horizontal or vertical wells.” Reporting must be in accordance with 19.15.16.17 (C-103) and or 19.15.29 NMAC (on a C-141 form).
The NMOCD further states that “completion operators will be required to IMMEDIATELY report any instances of inter-well communication resulting from stimulation. Releases must be reported on a C-141 form while only pressure increases or decreases must be reported on a C-103 form.”
Affected operators must also IMMEDIATELY report any instances of inter-well communications on a C-141 form and they are also advised to contact the operator performing the stimulation.
Note that the NMOCD provides a “clarification” that “any fluid or gas released from an affected well will be considered a release. This includes but is not limited to, any mixture of completion and/or formation gases vented from the production equipment due to the inter-well communication.”
